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Technical Interpretation - Internal

10 April 2014 Internal T.I. 2014-0522091I7 - Whether aquaculture is farming under the Act

The Queen: It seems clear on reading the definition of farming in sec. 248(1) … that, since "farming" is defined as including the raising of poultry, together with other various agricultural activities, the enumeration of these matters is not intended to constitute an exhaustive definition and one must look to the common, ordinary and generally accepted meaning of the word as well as to the specific activities detailed in the statute. ...
Technical Interpretation - Internal

7 May 2014 Internal T.I. 2014-0528251I7 - Surface Rentals for Wind Farms

Please refer to paragraph 7 of Interpretation Bulletin IT-433R, Farming or Fishing – Use of Cash Method. ...
Technical Interpretation - Internal

8 November 2012 Internal T.I. 2012-0440231I7 - common-law partner

November 8, 2012 Colette Fournier Income Tax Rulings Directorate Programs Officer Financial Industries Division Training & Content Support Section Nancy Shea-Farrow Taxpayer Services Directorate 905-721-5099 2012-044023 Subject: Common-law partners This is in response to your e-mail on March 15, 2012 asking what marital status should be indicated on an individual's income tax return (the "return") in the following situation. ...
Technical Interpretation - Internal

29 January 2015 Internal T.I. 2014-0544651I7 - Section 85 transfer of Swap Contracts

Moore for Director Partnerships & Corporate Financing Section International Division Income Tax Rulings Directorate Legislative Policy and Regulatory Affairs Branch cc XXXXXXXXXX, Income Tax Audit XXXXXXXXXX Tax Services Office ...
Technical Interpretation - Internal

9 April 2013 Internal T.I. 2012-0480021I7 - Section 35--Prospectors

Canadian Pipelines & Petroleums Limited [1960] S.C.R. 126). Provided that the mining claims qualify as a "right to explore for minerals in a mineral resource in Canada", it is our view that the shares received by Mr. ...
Technical Interpretation - Internal

24 October 2014 Internal T.I. 2013-0473751I7 - Gold Indian investment

The Canada Revenue Agency's Interpretation Bulletin IT-346R establishes an administrative position which allows a person who meets the definition of "speculator" at 6 of the Bulletin to elect to report the income resulting from such transactions, for income tax purposes, as being on account of capital instead of income. ...
Technical Interpretation - Internal

21 May 2015 Internal T.I. 2015-0567981I7 - Refundable ITC

As we advised you in XXXXXXXXXX, the CRA has accepted the Federal Court (the "Court") decisions in Signalgene R & D Inc. v. ...
Technical Interpretation - Internal

7 March 2016 Internal T.I. 2015-0572461I7 - Foreign tax deduction

Facts The facts, as we understand them, are as follows: Taxpayer, a Canadian citizen and a resident of Canada for purposes of the Act and the Canada U.S. ...
Technical Interpretation - Internal

29 September 2011 Internal T.I. 2011-0420701I7 - Interest on a Taxpayer Requested Adjustment

29 September 2011 Internal T.I. 2011-0420701I7- Interest on a Taxpayer Requested Adjustment Unedited CRA Tags s. 161(7)(b)(ii) & (iv) Principal Issues: What is the date to be used when calculating interest where Years 1 to 7 were reassessed, resulting in losses being converted to income, and the taxpayer states during the audit that it would be applying losses for the current year to reduce taxable income in one of those reassessed years? ...
Technical Interpretation - Internal

26 April 2016 Internal T.I. 2015-0623571I7 - one-time salary transition payment

For more information regarding the repayment of a salary advance, see “salary overpayments” in chapter 6 of CRA Guide RC4120, Employers’ Guide Filing the T4 slip and Summary. ...

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